Liberi v Taitz 02.07.2011 Reply to Response 2
APPELLANTS’ REPLY TO APPELLEES’ RESPONSE
On 02.01.2011 Appellees filed a response. There is a discrepancy between thenotation on the docket and the caption on the response itself.The docket states:
02/01/2011 ECF FILER: Response filed by Appellees Evelyn Adams, Philip J. Berg, Go ExcelGlobal, Law Ofc of Philip J. Berg, Lisa Liberi and Lisa M. Ostella in Opposition toMotions to recuse Judges Greenaway and Jordan
and for judicial notice
& Motion forAttorney Fees in the amount of $5,000 for time spent in responding to the motions.Certificate of Service dated 02/01/2011. --[Edited 02/02/2011 by AWI] (PJB)
The caption on the pleadings does not include words “Judicial notice”. It is
possible, that it was accidentally omitted, therefore the Appellants reply to theopposition on all accounts.
REPLY TO THE OPPOSITION TO JUDICIAL NOTICE
First document in the Judicial notice is the transcript of the hearing held on12.20.2011 in front of Judge Robreno. Appellees themselves made thisnotice a part of the proceedings, as they filed a motion for TRO with theThird Circuit Court of Appeals, accusing Appellants of committing multiplecrimes. Third Circuit Court of Appeals referred this matter to the DistrictCourt for hearing, thus this hearing became an integral part of the Appeal.If the transcript and the disposition of the hearing are not reviewed by theThird circuit Court of Appeals, the Third Circuit would be prejudiced againstthe Appellants. The Transcript is absolutely essential for the Appeal. Theessence of the appeal is that the Plaintiffs/Appellees committed fraud byclaiming that the Plaintiff/Appellee Lisa Liberi is the resident of PA, not LisaLiberi, who was convicted in 2008 in CA and who is on probation under thesupervision of the San Bernardino, California Department of Probations.
The court erroneously assumed jurisdiction in this case, based on afraudulent assertion by Liberi and her attorney Berg.
Case: 10-3000 Document: 003110433419 Page: 2 Date Filed: 02/09/2011